REPUBLIC OF THE PHILIPPINES
FAMILY COURT
NATIONAL CAPITAL JUDICIAL REGION
BRANCH 1- MANILA CITY
MOTION FOR EXTENSION OF TIME
DEFENDANT, by the undersigned counsel, and unto this Honorable Court, most
respectfully states that:
1. Defendant engaged the services of undersigned counsel only on
November 9, 2020;
2. Defendant was served with Summons and copy of the Complaint on October
15, 2020, and thus has until November 14, 2020, within which to submit an
Answer or Responsive Pleading;
3. However, due to the pressures of equally urgent professional work and prior
commitments, the undersigned counsel will not be able to meet the said
deadline;
4. As such, undersigned counsel is constrained to request for
an additional period of ten (10) days from today, November 9, 2020,
within which to submit Defendant's Answer or Responsive Pleading or until
November 19, 2020. Moreover, this additional time will also allow the
undersigned to interview the available witness and study this case further;
5. This Motion is not intended for delay but solely due to the foregoing
reasons.
PRAYER
WHEREFORE, Defendant most respectfully prays of this Honorable Court that he
be given an additional period of ten (10) days from today November 9, 2020 or
until November 19, 2020, within which to submit an Answer or other Responsive
Pleading.
Other relief just and equitable are likewise prayed for.
Manila City, Philippines, November 19, 2020.
Omar S. Alhadramy
Counsel for Petitioner
654 Recto Ave., Sta Cruz, Manila
PTR No. 258369 / 01-05-2021
IBP No. 147258 / 07-18-2020
Attorney’s Roll No. 54321
MCLE No. V-0800589